Web Privacy Policy

Purpose of this privacy notice Controller This policy covers all Urban&Civic companies and any subsidiaries that act as a Data Controller, including personal data processed in relation to this website and to the other websites referenced in the Glossary

This notice also covers our specific project sites, as well as public engagement and consultation websites that we may establish from time to time. Where such websites involve the processing of personal data, you will see a copy of this notice and our contact details as below.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

Urban&Civic plc 115 George Street, Edinburgh, EH2 4JN info@urbanandcivic.com

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This policy is effective from 25 May 2018. If we make changes to this policy, the updated version will be posted on our webpage in a timely manner and, if we make material changes, we will provide a prominent notice. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

This website may include links to third-party websites, plug-ins and applications or store cookie files on your computer in order to deliver its service(s). Clicking on those links or enabling those connections may allow third parties to collect, store or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Personal data, or personal information, means any information about an individual from which that person can be identified.

We may collect, use, store and transfer the following different kinds of personal data about you:

• Identity Data includes first name, last name, username or similar identifier, title, data of birth and gender, and also includes photographs taken at Urban&Civic events and CCTV images captured at our sites.
• Contact Data includes billing address, delivery address, email address and telephone numbers, and any contact details you provide on our specific enquiry or engagement forms either on the website or at our physical sites.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username or similar identifier and password, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Communications Data includes all communications we have with you whether by email, post, phone or otherwise, including any ‘show your support’ and ‘ask a question’ form information, as well as any feedback given directly to our site-based teams on in comment form responses on our public consultation and engagement websites. If you fail to provide personal data Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise.

  This includes personal data you provide when you:

  • apply for our products or services;
  • create an account on our website;
  • attend one of our sites or events;
  • engage with our public consultation process;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below.

• Technical Data from the following parties:

  1. Analytics, storage, tools and media providers based in and outside the EU;
  2. IP tracking service providers based within the EU;
  3. automated quality control tools based within the EU;
  4. automated security and compliance tools based outside the EU;
  5. social media and media networks such as Twitter, LinkedIn, Instagram, YouTube and Vimeo based outside the EU; and f. email distribution and survey providers based outside the EU;
• Identity and Contact data from providers of data feeds and hosting services provided inside the EU and outside of the EU, third-party photographers engaged at our sites and events.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

1. To register you as a new customer

   Type of data

   1. Identity
   2. Contact Lawful basis for processing including basis of legitimate interest Performance of a contract with you

2. To process and deliver your order, including managing payments, fees and charges, and collecting and recovering money owed to us

   Type of data

   1. Identity
   2. Contact
   3. Financial
   4. Transaction
   5. Marketing and Communications

   Lawful basis for processing including basis of legitimate interest

   1. Performance of a contract with you
   2. Necessary for our legitimate interests (to recover debts due to us)

3. To manage our relationship with you

   This includes:

   1. Notifying you about changes to our terms or privacy policy
   2. Asking you to leave a review or take a survey
   3. Answering any queries you may have

   Type of data

   1. Identity
   2. Contact
   3. Profile
   4. Marketing and Communications

   Lawful basis for processing including basis of legitimate interest

   1. Performance of a contract with you
   2. Necessary to comply with a legal obligation
   3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
   4. To deal with your enquiries

4. To enhance our photo library, to illustrate presentations, reports and our websites

   Type of data

   1. Identity (image)

   Lawful basis for processing including basis of legitimate interest

   1. Necessary for our legitimate interests (to develop our website, record site progress, market and record our events and grow our business)
   2. Your consent

5. To enable you to partake in a prize draw, competition or complete a survey

   Type of data

   1. Identity
   2. Contact
   3. Profile
   4. Usage
   5. Marketing and Communications

   Lawful basis for processing including basis of legitimate interest

   1. Performance of a contract with you
   2. Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

6. To administer and protect our business and this website This includes troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

   Type of data

   1. Identity
   2. Contact
   3. Technical

   Lawful basis for processing including basis of legitimate interest

   1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
   2. Necessary to comply with a legal obligation

7. To receive feedback on consultation events, to engage with local communities and receive feedback on the progression of ongoing events

   Type of data

   1. Identity
   2. Contact
   3. Profile

   Lawful basis for processing including basis of legitimate interest

   1. Necessary for our legitimate interests (to understand and grow our business and to inform our marketing strategy)
   2. Necessary to comply with a legal obligation

8. To deliver relevant website content to you and measure or understand the effectiveness of our website

   Type of data

   1. Identity
   2. Contact
   3. Profile
   4. Usage
   5. Marketing and Communications
   6. Technical

   Lawful basis for processing including basis of legitimate interest Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

9. To make suggestions and recommendations to you about goods or services that may be of interest to you

   Type of data

   1. Identity
   2. Contact
   3. Technical
   4. Usage
   5. Profile

   Lawful basis for processing including basis of legitimate interest Necessary for our legitimate interests (to develop our products/services and grow our business)

10. To provide regulatory news via an automated email alert service

    Type of data

    1. Identity
    2. Contact Lawful basis for processing including basis of legitimate interest Necessary for our legitimate interests and as you have requested to receive RNS announcements

    Marketing

    We strive to provide you with choices regarding certain personal data uses, particularly around marketing and communications. We have established the following personal data control mechanisms:

    Promotional offers from us

    We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

    You will receive marketing communications from us if you have requested information from us, purchased goods or services from us or expressed an interest in our products and, in each case, you have not opted out of receiving that marketing.

    Third-party marketing

    We will get your express opt-in consent before we share your personal data with any company outside the Urban&Civic group for that third party’s marketing activities.

    Opting out

    You can ask us to stop sending you marketing messages at any time by contacting us. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or experience or other transactions.

    Cookies

    Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site about aspects of your visit. Most web browsers allow some control of most cookies through the browser settings. For more information about the cookies we use, please see our cookie policy.

We may have to share your personal data with the parties set out below for the purposes set out in the table in section 4 above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Wherever possible we do not transfer your personal data outside the European Economic Area (EEA).

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data may sometimes involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

In other cases, we may use specific contracts approved by the European Commission which ensure that your personal information is given the same protection it has in Europe. For further details and a copy of the relevant contracts, see the European Commission’s webpage on the model contracts for the transfer of personal data to third countries

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the EEA.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long will you use my personal data for? We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax and legal purposes.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Any subsidiaries, holding companies, associated companies, or affiliates of, or companies controlled by, or under common control within the Urban&Civic Group;

External Third Parties

• Digital service providers acting as processors, operating in the EU, who provide a number of services, including but not restricted to data feeds, hosting, SSL, data analysis, CRM, video streaming, social media and sharing services.
• Professional advisers including lawyers, bankers, auditors, planning consultants and insurers.
• HM Revenue & Customs, regulators and other authorities acting as processors based in the United

Kingdom who require reporting of processing activities in certain circumstances.

• Marketing services providers acting as processors including mailing and survey companies operating in and outside of the EU who provide distribution, reporting and analysis of emails and surveys.
• Parties who have an interest in contacting you and who you have provided your consent to receive updates from, including housebuilders and developers.
• Design consultants and publishers preparing reports or developing content for websites on our behalf.

YOUR LEGAL RIGHTS

You have the right to:

Request access

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.